Effective Date: June 1, 2020
At Brivo®, privacy and security are core elements of our service. Accordingly, we are always conscious and respectful of the privacy and confidentiality of individuals who visit Brivo’s websites (“Visitors”). Brivo Systems LLC and its subsidiaries are collectively referred to herein as “Brivo”.
The Site may contain links to other websites. The privacy statements of those websites govern the information practices and the content of those websites. Brivo encourages you to review the privacy statements of other websites to better understand their information practices.
- Personal information we collect through the Site.
- Personal information we collect about you in the course of interacting with you, such as when you engage with us as a customer, potential customer, vendor, service provider, potential partner, partner, applicant, consultant, contractor or other third party in relation to the operation of our business generally. This includes sales, marketing, business contact and/or registration activities conducted by Brivo.
Collectively this is considered “Visitor Data”.
Collection and Use of Visitor Data
Information you voluntarily provide us
Brivo only collects the personal information necessary to enable us to respond to your requests for our products and services. When you use our Site, complete forms, schedule a demo, respond to a survey, complete a partner application, contact us or otherwise interact with our business, we usually collect personal information such as your name, e-mail address, postal address, company name, telephone number and any other information you choose to optionally provide that will enable us to respond as requested to you.
You can opt out of providing personal information by not entering it to the Site or otherwise not providing it if asked.
Information which we collect automatically:
We do not deliver third party online advertisements on our Site, but we may use third-party advertising companies to serve ads for our services when you access and use other websites, based on the information relating to your access to and use of our Site, as well as information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser during your visit to the Site.
Google Analytics is a web analysis service provided by Google that utilizes cookies to monitor web-traffic on our Site. We use Google Analytics to collect, track and examine data about the Site’s usage. We may run reports based on the data we collect and we may share the data with other Google services. Google may use the data to personalize and customize the advertisements that are served to you from its advertising network. The Site does not respond to Do Not Track Signals from browsers.
We only use your information as permitted by applicable law. We may combine information that we collect with information from external sources. We may use your information to:
- Promote use of our services to you and others or to send you marketing materials
- Distribute subscribed news and information notices to enrolled email addresses (including a link to unsubscribe)
- Obtain your feedback on our Site
- Statistically analyze user behavior and activity and to improve the Site or services
- To communicate with you and provide customer support
- Obtain your consent for a specific use
Who We Share Your Information With
Brivo may share or transfer information you provide to us or that we collect on the Site.
Business-related transfers. Brivo may share your information to other businesses that we acquire, are acquired by, or with which we merge or partner.
Service Providers. We may transfer information to third parties with whom we contract to support our activities, including maintaining and managing our end-user information.
Compliance with Laws. Brivo may determine that we need to share your information with law enforcement or other governmental authorities in order to comply with law or the legal process.
Protect Our Rights. Brivo may share your information to protect our rights and property. For example, we may share information if we believe it will prevent the misuse or unauthorized use of the Site, protect the personal safety or property of our users or the public, or in the event of bankruptcy proceedings.
Data Location and Safeguards
Brivo stores all Visitor Data in the continental United States. Brivo maintains a comprehensive, written information security program that contains industry standard, administrative, technical, and physical safeguards designed to prevent unauthorized access to Visitor Data. However, because no security measures are perfect or impenetrable, we cannot guarantee the security of information you submit to us.
Accountability for Onward Transfer of Personal Data
Except as otherwise provided herein, Brivo may share personal information with third parties in connection with the operation of our business and consistent with the purpose for which the personal information was collected. Except as permitted or required by applicable law, Brivo maintains written contracts with these third parties and requires them to provide at least the same level of privacy protection and security as required by the Privacy Shield Principles. To the extent provided by these Principles, if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles Brivo shall be responsible and liable unless Brivo proves that it is not responsible for the event giving rise to the damage.
Brivo retains Visitor Data in accordance with our data retention policies and practices. The length of time we keep your information depends upon a number of factors, including the type of information. In general, we retain personal information for as long as we have an ongoing business need to retain it. Following that period, we will delete it.
If Brivo becomes aware of any improper access, unauthorized use or disclosure of Visitor Data (a “Data Breach”), Brivo will analyze the facts of the Data Breach in the context of applicable laws, regulations, policies and contractual obligations to determine the appropriate notification process. Brivo will conduct notifications in a timely manner after becoming aware of a Data Breach and take commercially reasonable steps to minimize harm and mitigate further risks to Visitor Data.
Privacy Shield Commitment
U.S. Federal Trade Commission enforcement
Brivo’s commitments under Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
In compliance with the Privacy Shield Principles, Brivo commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Brivo at: firstname.lastname@example.org or by calling us at +31 20 8880980 (The Netherlands) or + 1 301 664 5242 (USA).
Brivo has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States and around the world. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shieldfor more information or to file a complaint. The services of JAMS are provided at no cost to you. If neither Brivo nor our dispute resolution provider resolves your complaint, you may have the possibility to engage in binding arbitration through the Privacy Shield Panel.
Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For additional information please go to the Privacy Shield website at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Users from the European Economic Area
Legal Basis for Processing. If you are an individual resident in the European Economic Area (“EEA”), we collect and process information about you only where we have a legal basis for doing so under applicable European Union laws. The legal basis depends on how you use the Site:
- We need to collect and use the information to provide our services to you;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests; or
- You give us consent to do so for a specific purpose.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the services.
How to Access or Control Your Information – The General Data Protection Directive (“GDPR”) grants individuals residing in the EEA certain rights with respect to their information. These include the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. You can exercise these rights by contacting us at the address in the Contact Section below.
The GDPR provides that we may limit or deny your requests in certain cases. For example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we have compelling legitimate interests to keep, including as required by law. You may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed if you have concerns about your rights.
Other International Users
The Site is hosted in the U.S. If you are a consumer accessing the Site from Asia, or any other region with laws or regulations governing personal data collection, use and disclosure that differ from U.S. laws, your continued use of the Site, which is governed by U.S. law and these terms, indicates your consent to transfer of your information to the U.S.
Because protecting the privacy of young children is especially important, we do not knowingly collect or maintain information from or about persons under 13 years of age. No part of our Site is structured to attract anyone under 13. If you are under 13, do not use or access the Site at any time or in any manner. If we learn that personal information of persons under 13 has been collected on the Site without verified parental consent, we will take appropriate steps to delete this information.
Brivo Privacy Officer
Brivo Systems LLC
7700 Old Georgetown Road, Suite 300
Bethesda MD, 20814 USA
YOUR CALIFORNIA PRIVACY RIGHTS (FOR CALIFORNIA RESIDENTS ONLY )
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our CCPA Privacy Notice page.
Changes to this Privacy and Security Policy